We are governed by the Privacy Act 1988 (Cth) (Act) and apply the Australian Privacy Principles (APPs) as our standard for the collection and use of your personal information. You can find out more information about the Act and the APPs at the Office of the Australian Information Commissioner’s website at www.oaic.gov.au.

While we believe in keeping your personal information highly secure, we also believe that you have the right to be informed about how we deal with that information so, if on reading this Privacy Policy you are unclear on any of the matters or simply want more information, please contact us on the details provided below.

This Privacy Policy tells you about the ways in which we collect your personal information and how we use and disclose that information.

Unless it is unreasonable and impracticable to do so, we collect your personal information from you directly, including by using cookies on our website and through monitoring your purchasing behaviour.

In some cases we may collect information from other third parties such as your hospital, treating physician or other health practitioner. At the time of collection, or as soon as practicable after we have collected it, we will take reasonable steps to notify you of the collection and of any matters relevant to the collection.

When you visit our Website, Slade generally does not require you to provide personally identifiable information. However, in order to participate in some activities such as our online promotions, to access specific sections of our Website, to create an account on our Website or to contact us, you must provide us with the information we request to enable us to process your query.

To create an account on our Website, you consent to our collection of the information you provide to us, including the following information:

name;

email address;

address; and

telephone number.

In order to apply to become a member of the SladePlus Program and to receive a SladePlus Card, you must provide to Slade Marketing, at a minimum, your name, address, gender, date of birth and mobile phone number. We may also collection your email address. Failure to provide the required information may result in refusal of your application to join the SladePlus Program.

If you receive goods and/or services supplied by us, either through our Website or by email, over the phone, in person with one of our pharmacists or at a hospital at which we supply goods and/or services, or by fax, we will collect “sensitive information” from you. Sensitive Information has the meaning given to that term under the Act, and it includes Health Information” as defined under the Act. In addition to the personal information specified above, you consent to our collection of the following sensitive information, including:

credit card and billing information;

your Medicare number (if you are a patient) or your provider number (if you are prescribing medication to a patient);

private health fund information;

relevant statutory entitlements or programs that are relevant to you;

details of medications prescribed to you by your treating doctor or medications that you prescribe to your patients;

details about your medical, fertility history and general health; and

in some jurisdictions we are required to collect information like your driver’s licence number when supplying medicines containing pseudoephedrine.

Much of the information we ask for is because the law requires it to be collected. For example, the law requires us to collect personal details contained in prescriptions (which is where we get most of our information about you).

If you decide not to provide us with the required information, we may be unable to process your request or provide you with the goods or services you have requested.

Within some pages of our Website you are able to initiate a request for additional information or to commence dialogue with Slade. In these circumstances, in addition to the information set out above, we may also ask for information about your preferences or relevant areas of interest.

Naturally, we collect and hold a broad range of personal information gathered during the course of providing our goods/services. However as stated above, we strive to ensure that we collect and hold only that personal information which is relevant and necessary to your specific matters.

If you plan to order products or services from us using our Website please refer to our Terms and Conditions of Sale before placing an order with Slade. Please contact us to obtain a copy Terms and Conditions of Sale.

4 Information collected through normal browsing of our Website

When you use our Website, your IP address, the referring website URL and the date and time of file requests to which information is sent may be collected automatically. This information is used to monitor activity within our Website which is in turn used for our internal purposes to maintain and improve the quality of information that we display.

5 Cookies

A cookie is a piece of data stored on a user’s hard drive containing information associated with the user. We use cookies to be reminded of who you are and to access your account information (stored on our computers) in order to deliver to you a better and more personalised service. This cookie is set when you register. Slade does not and will not use cookies or any other technology to track or report on visitor activity when they are not on the Website, nor do we transfer visitor data to other websites. Slade uses visitor data to measure Website activity, and to determine the features that are important and relevant to visitors to the Website so that we may develop new and improved services in the future.

6 Purpose of collection

We collect and hold your personal information primarily to provide or offer our goods or services to you, or if it is reasonable to expect that we would use or disclose your personal information for purposes which are related to that primary purpose.

If you are a member of the SladePlus Program, or otherwise with your consent, we may also use your personal information to:

send newsletters to you;

invite you to seminars or events hosted by Slade;

inform you of products that can be purchased from Slade; or

inform you of products and/or services that Slade can provide, including through the SladePlus Program.

If you decide at any time that you do not wish to receive the above information from us, please contact us at privacy@slade.net.au and we will remove your email address from our mailing list.

7 How we use your information

Once collected, we may use the personal information you provide to us in the following ways:

to provide goods and services to you;

to create and administer your online account;

to create and administer your SladePlus Program membership;

to answer your emails or your enquiries made through the Website;

to enter you in or notify you about a promotional campaign;

to notify you about new features on our Website or new products or services;

to customise your experience on our Website and to improve its features, products and services;

to deliver other services to you, such as newsletters, or any other information that we may consider to be of interest to you;

to send you surveys or questionnaires;

to directly market our goods and services to you (unless you tell us not to direct market to you); and

for other business purposes such as statistical and research purposes.

Personal information that is collected by us for the sole purpose of dispensing prescriptions to you will not be used for marketing purposes without your consent. If at any time you wish to opt out of email correspondence that we send to you, click the “unsubscribe” link at the bottom of any email received from Slade.

To opt out of any correspondence you receive from us via post or by any other means, please contact us at the details below and we will take you off our mailing list.

We may store the information we collect from you indefinitely. Other than as set out in section 7 of this Privacy Policy, Slade will not provide this information to any other company for that company’s independent use.

8 How we disclose your information

We will disclose your personal information to the following third parties:

companies related to us that are located in Australia, including Slade Pharmacies (including SladePlus Pharmacies);

to certain statutory bodies as required under legislation, including in response to a subpoena request, to assist police in an official investigation or where patient safety may be at risk;

IT technicians who may need to have access when providing on-site support (although it is our usual practice for them to work under supervision); and

file storage service providers.

If you are a member of the SladePlus Program, or otherwise with you consent, we may also disclose your personal information to the following third parties:

our agents and partners with whom we work for the purposes of providing promotional programs;

third party contractors that provide software or services for the operation of the SladePlus Program from time to time, including Magikos Marketing Pty Ltd (ACN 168 307 640) trading as KnowItAll Loyalty Systems (KIALS);

In relation to the SladePlus Program, KIALS’s handling of your personal information is dealt with in accordance with its own Privacy Policy which can be found on its website, however, in general, Slade Marketing, the SladePlus Pharmacies and KIALS will not sell, rent or lease your personal information which is collected for the purpose of administering your membership in the SladePlus Program, to third parties, and they will only disclose your personal information to third parties where necessary in order to facilitate the provision of goods and services pursuant to the SladePlus Program.

We are not likely to disclose your personal information to overseas recipients and would only do so in accordance with legal requirements.We will not otherwise disclose personal information about you unless the disclosure:

is required by law;

is authorised by law; or

you have consented to our disclosing the personal information about you.

9 Personal information quality

We aim to ensure that your personal information is accurate, complete and up to date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested and properly update the information to us to keep it true, accurate, current and complete.

If you believe that the information we hold about you is inaccurate or incomplete, please contact us and we will use all reasonable efforts to correct the information.

If we believe the information to be incorrect, we will take reasonable steps to add a statement to the information claiming that you believe the information is not accurate, complete or up-to-date.

10 How we safeguard your information

We are committed to maintaining the security and confidentiality of the data you provide us and we will take reasonable precautions to protect your personal information from unauthorised disclosure, use or alteration.

We have the following security measures in place to protect your information:

our offices are also securely locked after hours;

all computers have password protection;

all computers linked to our intranet are password protected and virus protected;

our offices are monitored regularly by a security service;

our website is protected by a firewall; and

our employees all sign confidentiality agreements as part of beginning employment at Slade.

11 Accessing your personal information

You may request access to or correction of the personal information that we hold about you.

We will give you access to, or correct, your personal information unless there is a lawful reason for refusing your request for access or correction. If we refuse your request we will give you a written notice explaining our reasons for that refusal and how you may complain about that refusal.

You may review and update or correct your information by contacting Slade at privacy@slade.net.au.

12 Are you under 18 years of age?

We do not want to collect personal information from visitors to our Website who are under the age of 18 years of age. If you are under 18 years of age, you should not enter any information on our Website.

13 We may change this Privacy Policy

This Privacy Policy is not a static document. We may change the terms of this Privacy Policy at any time. If we change this Privacy Policy we will post the revised Privacy Policy on our Website. We recommend that you review this Privacy Policy whenever you visit our Website.

14 Change in control of Slade

If we sell or otherwise transfer part or the whole of Slade or our assets to another organisation (including in the course of a transaction like a sale, merger or acquisition or as part of a dissolution, liquidation, administration, receivership or other form of insolvency), you agree that your personal information that is collected by Slade may be disclosed to a third party, prospective buyer, transferee or insolvency practitioner and that this is reasonable to enable that party to continue or manage the business.

15 Complaints

If you have a complaint about our collection, use or disclosure of your personal or sensitive information, or you wish to make a complaint about a breach of the APPs, please contact our Privacy Officer at the details set out below detailing the nature of your complaint. We take your privacy seriously and we will review the details of your complaint and use our best endeavours to deal with your complaint sensitively and in a timely manner.

You can also make a complaint to the Office of the Australian Information Commissioner. Further information is available at www.oaic.gov.au.

16 Contacting us

If you would like further information regarding this Privacy Policy, or if you have concerns about the information that we currently hold about you, or any aspect of this Privacy Policy, please contact the Privacy Officer at: